this time is unavailing. As noted below, at the very least, the city limits parameters were <br />obtained from the Lane Council of Governments and "digitized manually." See attached <br />Map SA 7.0, note 2. <br />The applicant's new maps (ZC-4A through D) are not responsive to LUBA's remand <br />After explaining its new maps, the applicant alleges that "[t]here is no perfect <br />alignment" and there is "[n]o magic location where everything aligns." This is <br />unremarkable because, as LUBA understood, the goal is accuracy, not perfection. The <br />applicant's basic conclusion is that the Hearing Official should rely on the map ZC-4A, <br />which is the same map as Exhibit L that the Hearing Official relied upon in his prior <br />decision. As noted below, in light of the Hearing Official's prior findings and LUBA's <br />direction to consider various referents and other information to accurately delineate the <br />line between plan designations, the Hearing Official should find that LHVC's 9/2/15-04 <br />map is the most accurate because it attempts to utilize all referents. <br />The basic problem with the applicant's new maps is that they attempt to only <br />center on a single referent, instead of reconciling imperfections so that the various <br />referents can all be used to find the most accurate delineation. They maps use a "main <br />referent." This simply repeats the error that LUBA remanded. For example, ZC-4A's <br />main referent is the 30th Avenue center line; ZC-413's main referent is the green finger; <br />ZC-4C's main referent is the center line of Spring Boulevard; and ZC-4D's main referent <br />is Bloomberg Park. In each map, the applicant is, again, using only a single referent with <br />the point being that there is no perfect fit. Again, the issue is not perfection but rather <br />accuracy. The applicant's failure to learn from LUBA's remand is problematic, and, <br />therefore, the Hearing Official should reject the applicant's maps. <br />LHVC's prior submitted map and newly submitted map are the most accurate maps <br />before the Heariniz Official <br />It is notable that the Hearing Official previously found that LHVC's maps were <br />more compelling than the applicant's maps: <br />"LHVC produced maps showing much more POS designated land by using a <br />version of the Metro Plan diagram obtained from LCOG that are depicted in <br />Exhibits 1-5 to their letter of September 2, 2015. LHVC also uses tax lots for <br />other properties, city limits, and additional streets to generate what it argues are <br />more accurate maps than the applicant. LHVC materials were prepared in part by <br />a certified engineering geologist, and the arguments are compelling. In fact, if the <br />question were where the boundary is most likely located using any available. <br />Information, I would likely agree with LHVC. In determining a boundary, <br />however, we are all bound by the 2004 Metro Plan diagram. As staffs September <br />2, 2015 memorandum explains, LHVC used maps generated by LCOG from a <br />digital version that is different from the 2004 Metro Plan, even LCOG <br />3 <br />